Skip to content
Funds

Direct Plan Recommendation Obligations — Why an IA Must Always Point Clients to Direct Plans

Why SEBI's Investment Adviser framework specifically requires recommending direct (non-commission) plans wherever available — and what this means for how you document product recommendations.

18 Jul 20263 min read

A Rule That Reinforces the Entire Fee-Only Framework

Scattered across our earlier articles on client-level segregation and the fee-only structure SEBI's IA framework is built around, one specific, recurring obligation ties it all together operationally: wherever a direct plan version of a product is available, an IA must recommend it over the commission-bearing regular plan.

What "Direct Plan" Actually Means

Most mutual fund schemes (and certain other products) are available in two variants — a regular plan, which pays ongoing trail commission to a distributor, and a direct plan, which carries no distributor commission and, correspondingly, a lower expense ratio for the investor. The economic difference compounds meaningfully over a long holding period, even though the difference in any single year can look small.

Why This Obligation Exists

If an IA — compensated purely through client-paid advisory fees, not product commission — were to recommend a regular plan where a direct plan of the identical underlying scheme is available, there's no economic justification for that choice from the client's perspective. The IA gains nothing from the regular plan's commission (since IA compensation is fee-only, not commission-linked), so recommending it anyway would simply cost the client more for no corresponding benefit — precisely the kind of misaligned recommendation the entire IA framework is designed to eliminate.

This Isn't Just Good Practice — It's a Specific Compliance Expectation

While this obligation flows from the broader fee-only, fiduciary structure of IA regulation rather than existing as an isolated standalone rule, it's treated as a specific, checkable practice during compliance review — recommendations that steer clients toward regular plans without clear justification are a red flag precisely because they're economically inconsistent with a genuinely fee-only advisory relationship.

Documenting Compliance With This Obligation

For every product recommendation involving a scheme available in both plan variants, your advisory records should clearly reflect that the direct plan was recommended — and where, in a genuinely unusual circumstance, a regular plan was somehow involved (for instance, a client already holding regular-plan units from before the advisory relationship began), the reasoning for that specific situation should be documented rather than left ambiguous.

What This Means for Reviewing a Client's Existing Portfolio

Where a new client comes to you already holding regular-plan investments from a prior distributor relationship, your advisory role includes flagging this cost inefficiency and recommending a switch to the direct-plan equivalent, subject of course to considering any switch-related tax or exit-load implications specific to that client's holdings — the direct-plan obligation applies to your ongoing advisory guidance, not merely to fresh product recommendations.

Why This Matters for Your Own Practice's Audit Trail

At annual compliance audit stage, reviewers will typically sample advisory recommendations and check for consistent direct-plan steering — a pattern of regular-plan recommendations without documented justification is one of the clearer, more objectively testable compliance findings an auditor can identify, precisely because there's little room for judgment-based justification once the fee-only economics are laid out.

Building Direct-Plan Compliance Into Your Advisory Process

We help IAs build recommendation documentation practices that clearly evidence direct-plan compliance, and review existing client portfolios for legacy regular-plan holdings that should be flagged as part of ongoing advisory service.

Want your advisory records reviewed to confirm direct-plan compliance is properly evidenced across your client base? Talk to Anuj Desai & Associates.

This article is for general informational purposes and does not constitute investment or regulatory advice specific to any adviser's recommendations.

direct plan obligation investment adviserIA must recommend direct plansdirect plan recommendation SEBIdirect plan mutual funds Indiadirect plan mutual fund advicedirect vs regular plan SEBI IAdirect vs regular mutual fundregular vs direct mutual fundfee only adviser direct plan rulefee only investment adviser Indiainvestment adviser commission conflict rulecommission conflict Investment Adviserconflict of interest Investment Adviserfiduciary duty Investment Adviserclient first advisory IndiaSEBI direct plan compliance requirementdirect plan compliance Investment Adviserdirect plan documentationdirect plan audit trailinvestment advisory recommendations IndiaInvestment Adviser product recommendationproduct recommendation compliancemutual fund recommendation compliancedirect plan requirement Indiadirect plan regulations Indiaregular plan commissionmutual fund trail commissiondistributor commission mutual fundsno commission advisory Indiafee only advisory model Indiainvestment advisory compliance IndiaInvestment Adviser compliance IndiaSEBI Investment Adviser RegulationsSEBI Master Circular Investment AdviserInvestment Adviser Master CircularRegistered Investment Adviser IndiaRIA compliance IndiaSEBI registered Investment AdviserSEBI regulated Investment Adviseradvisory services Indiawealth management compliance Indiafinancial advisory compliance Indiasecurities law compliance Indiaregulatory compliance Indiaadvisory business complianceInvestment Adviser operational complianceInvestment Adviser governanceInvestment Adviser internal controlsInvestment Adviser compliance checklistInvestment Adviser best practicesInvestment Adviser documentationadvisory documentation Indiaadvisory record keepingInvestment Adviser recordsadvisory workflow Indiaclient portfolio reviewportfolio review complianceexisting portfolio reviewlegacy regular plan reviewregular plan to direct plan switchswitch to direct planmutual fund switch tax implicationsexit load mutual fund switchmutual fund expense ratiolower expense ratio direct planinvestor cost savingsinvestment advisory suitabilityclient suitability Investment Adviserrecommendation rationale documentationinvestment recommendation recordsadvisory engagement documentationadvisory client filesInvestment Adviser compliance auditIA annual compliance auditIAASB complianceIAASB inspectionSEBI inspection readinessInvestment Adviser inspection readinessadvisory business operationsinvestment advisory legal complianceInvestment Adviser consultant IndiaSEBI compliance consultantInvestment Adviser compliance servicesInvestment Adviser registration consultantcompliance outsourcing Investment Adviserfinancial services compliance Indiainvestment advisory practice Indiaadvisory business growth Indiaadvisory process documentationadvisory governance Indiaethical investment advice Indiaclient centric advisorymutual fund advisory Indiadirect mutual fund investinginvestment advisory regulations IndiaAnuj Desai & Associates Investment Adviser Compliance
Share

Related insights

Funds

SEBI INVESTMENT ADVISERS COMPLIANCE CALENDAR FY 2026 27

This calendar captures the periodic reporting and audit requirements for SEBI‑registered Investment Advisers (RIAs) under the Investment Advisers Regulations, 2013, and the RIA Master Circular for FY 2026‑27. It covers the half‑yearly returns and net‑worth certificate for the two halves of the financial year and the annual compliance audit for the preceding financial year.

23 Jul 2026

Work with ADA

Ready to talk to an advisor?

Book a consultation and get a clear, considered view from a team that handles audit, tax, regulatory and cross-border work under one roof.